The Company makes this Statement pursuant to Section 54(1) of the Modern Slavery Act 2015 (‘the Act’) and constitutes the Company’s Anti-Slavery and Human Trafficking Statement for the current financial year.

Introduction

Available evidence suggests that modern slavery impacts almost every economic sector covering operations throughout manufacturing, the supply of services and transportation. While modern slavery is illegal in every country, the evidence also suggests that it still occurs in every country worldwide.

In recognition of this, and in order to support the aims and objectives of the Modern Slavery Act 2015, the Company publish an annual Statement confirming the steps that have been taken by the Company during the previous financial year to ensure that slavery and human trafficking is not taking place in any part of its business or its supply chains.

We confirm that the Company has not been convicted of breaching The Modern Slavery Act 2015 or had any notice served upon it, by any regulator or authority (including any local authority) during the accounting period covered by this Statement.

Organisational structure and supply chains

Turnover in the financial year ending 31 December 2023 was above the £36 million level required by the Act for the Company to publish a Modern Slavery statement on our website and this document sets out the latest update on our activities.

The principal activity of the Company during this period was provision of software licences and IT services.

The Company is wholly privately owned. Further details on the company structure are available on request.

Our supply chain consists of suppliers of software and related subcontractors instructed to carry out works and services on our project sites.

Due diligence processes

The Directors have undertaken a review of the Company’s supply chain and potential risks associated with material and labour procurement, whether this is connected to the aftermath of Brexit, Covid-19 or ongoing international conflicts.

The Company has a commitment to ensure that no slavery, servitude, forced or compulsory labour, or human trafficking, is taking place anywhere throughout Company’s operations or supply chains (including the supply of labour for any permanent or temporary position). Our due diligence processes include ensuring that any individuals working on our project sites have the right to work in the UK.

The Directors have concluded that the risk to its supply chain is low. This continues to be monitored on an ongoing basis.

Recruitment and Retention

Our recruitment process is undertaken with due regard to UK employment legislation, including, ‘Right to Work’ document checks; Contracts of Employment and checks to ensure that everyone employed is aged 16 and above. We expect our supply chain to operate the same policy and have the ability to demonstrate this.

The Directors are committed to treating their employees fairly and respectfully as they believe the Company is only as good as the quality of the employees it retains and develops. The Directors ensure that the Company is an equal opportunities employer and is fair to its employees in pay and benefits, health and safety at work and in the training and personal development offered. They believe it is important to develop a culture within the business so that its employees demonstrate the values, attitudes and culture desired when dealing with stakeholder relationships. This culture is led by the Directors in their dealings with employees.

Our Corporate Social Responsibility Policy is brought to the attention of our employees during induction and any individual responsibilities highlighted, in relation to supply chain selection. New employees are also expected to complete a training module on Modern Slavery as part of their induction.

Risk assessment and management

Where a risk is envisaged, i.e. due to the location of a supplier, an assessment will take place to ensure compliance with the Act. Where, due to specific industries, a higher risk of slavery is evident the Company will put measures in place to ensure sustainable sourcing is achieved by using only industry regulated and registered suppliers.

If a potential risk has been identified, the Company will assess and investigate the circumstances to ensure there is no breach of the legislation.

Effectiveness

The Company will undertake an annual review of the effectiveness of the steps it has carried out in the preceding financial year to ensure that sufficient action has been taken to prevent slavery and human trafficking within our supply chains and to highlight areas where improvements may be needed.

Training

It is the responsibility of the Board of Directors to provide adequate and appropriate resources to implement this Policy.

This Policy has been defined and approved by the Board of Directors.